Navigating work permits and expatriate migration in Kazakhstan in the construction and real estate sector: a step-by-step overview

Unlike migration frameworks in some OECD economies, where a single permit category covers most categories of skilled foreign worker, Kazakhstan operates a quota-based system in which authorisation to deploy an expatriate specialist must be secured at the employer level before the individual can legally commence work. For foreign companies active in Kazakhstan's construction and real estate sector — an industry that consistently attracts significant inbound investment and relies heavily on specialised foreign labour — this structural distinction has direct operational consequences. The quota regime, the role of Kazakhstan's Employment Centre, and the layered documentation requirements all sit within a framework that has undergone material reform in recent years, and the specifics differ meaningfully depending on whether the incoming worker is an EAEU national or a third-country national.

Before initiating any permit application, a foreign employer registered in Kazakhstan or operating through a local branch or subsidiary should confirm the following:

• Legal presence in Kazakhstan: a registered legal entity (LLP or branch), with a valid business identification number, is a prerequisite to obtaining a work permit quota. A foreign company cannot sponsor a permit as a non-resident entity alone.
• Verified headcount need: identify the specific roles, qualifications, and nationalities of all incoming specialists. EAEU nationals (Russian, Belarusian, Kyrgyz, and Armenian citizens) and non-EAEU nationals follow materially different tracks.
• Salary benchmarks: Kazakhstan's migration rules require that foreign specialists in most categories earn at least a prescribed multiple of the Kazakhstani minimum wage. Construction sector rates should be checked against the current regulatory minimum, which is updated periodically.
• Document readiness: educational diplomas, professional certifications, and employment contracts should be apostilled (where applicable) and professionally translated into Kazakh or Russian. Construction-specific technical licences may also be required depending on the role.
• Timeline buffer: the full permit cycle for a non-EAEU national from quota application to card issuance typically runs twelve to sixteen weeks in practice. Build this into project mobilisation schedules.

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The first and most consequential decision in any Kazakhstan work permit and expatriate migration exercise is whether the incoming workers are nationals of EAEU member states. Kazakhstan is a founding member of the Eurasian Economic Union, and citizens of Russia, Belarus, Kyrgyzstan, and Armenia benefit from a substantially simplified employment regime under the EAEU Treaty. They do not require a standard work permit and are not subject to the quota ceiling. An EAEU national may be employed in Kazakhstan without obtaining prior authorisation, subject to registration with the migration authorities within thirty days of arrival and compliance with standard labour contract formalities.

For construction and real estate projects that source labour from Russia or Kyrgyzstan — which is common across the Siberian and Central Asian supply chains — this distinction has a direct bearing on mobilisation cost and timeline. An employer deploying ten Russian welders and five Indian engineers faces two entirely parallel processes: the EAEU track for the Russian workers (registration only) and the full quota-and-permit track for the Indian nationals.

Third-country nationals — including citizens of China, Turkey, Germany, South Korea, and most other non-EAEU states — require a work permit issued under the quota framework. The employer must first obtain a quota allocation and then, against that allocation, process individual permits for each named worker. These two stages are sequential, not concurrent.

Note: EAEU-track employees are still subject to Kazakhstani labour law in full, including mandatory employment contract registration, social insurance contributions, and individual income tax obligations. Simplified entry status does not mean unregulated employment.

The work permit quota system is administered by the authorised employment authority under Kazakhstan's labour migration framework. Each calendar year, the government sets a national quota for foreign workers across economic sectors. Construction and real estate has historically been allocated a significant share of this quota, reflecting the sector's labour intensity, but allocation is not automatic.

An employer wishing to bring third-country national specialists to Kazakhstan must submit a quota application to the regional Employment Centre (the "Tsentr Zanyatosti") in the oblast or city where the work will be performed. For large construction projects spanning multiple regions — a common scenario in infrastructure and industrial real estate development — separate quota applications may be required for each operational zone.

The quota application must demonstrate: (a) a genuine operational need that cannot be met from the domestic labour pool; (b) an undertaking to pay the prescribed salary thresholds; and (c) confirmation of the company's registration and tax standing in Kazakhstan. Employment Centres retain discretion to require additional evidence, including documentation of prior recruitment efforts from the local market.

Quota approval is typically communicated within fifteen to thirty working days of a complete application. Quotas are employer-specific and role-category-specific — they cannot be transferred to another employer or repurposed for a different category of worker. If the scope of the project changes and additional roles are needed, a supplementary quota application is required.

Note: Quota exhaustion at the national level is a real operational risk. In prior years, the construction sector quota has been fully allocated before mid-year. Employers with a defined project mobilisation schedule should apply as early in the calendar year as the project pipeline permits. Late applications carry the risk of receiving a nil allocation for the remainder of that quota year.

Once a quota allocation has been confirmed, the employer proceeds to apply for individual work permits for each named third-country national. The work permit application is submitted to the Employment Centre and must include: the quota approval reference; a draft employment contract specifying position, remuneration, and duration; certified copies of the applicant's passport, educational credentials, and any professional licences relevant to the role; and medical certificates from approved Kazakhstani or recognised foreign medical institutions.

Work permits are role-specific, employer-specific, and location-specific. A permit issued for a project engineer on a residential development in Almaty does not authorise the same individual to work on a separate project in Astana, even for the same employer. For construction companies managing multiple concurrent sites, this granularity creates an administrative overhead that should be planned for from the outset.

The standard permit issuance period is up to thirty working days from the date of a complete application. Permits are typically issued for one year and are renewable. Renewals require the same documentation package as the initial application and should be initiated at least sixty days before the permit's expiry date to avoid a break in authorised employment.

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A work permit alone does not authorise a third-country national to enter Kazakhstan. Entry is via a business or work visa, obtained at a Kazakhstani consulate or diplomatic mission in the worker's home country. The visa application requires the issued work permit as a supporting document, along with the employment contract, a valid passport, passport photographs, and, in most cases, a medical certificate confirming freedom from communicable diseases.

Kazakhstan operates an e-visa system for nationals of a significant number of states; however, work-category visas for labour migration purposes are generally obtained through the consulate rather than the online portal. The processing time varies by consulate: two to ten working days is a reasonable estimate, though high-volume periods may extend this.

On arrival, the worker must register at their place of residence within three days. For construction projects where accommodation is provided at or near the site, the employer typically handles registration centrally. Failure to register within the statutory period attracts administrative liability for both the individual and the employer. For projects with large expatriate workforces, centralised registration management is strongly advisable.

EAEU nationals entering for employment are not required to obtain a work visa, but must notify the migration authorities of their arrival and register their place of residence within thirty days. They should also complete an employment notification with the relevant migration body within a prescribed period of commencing work.

Securing the permit and completing registration is not the end of the compliance cycle. Kazakhstan's migration and labour legislation imposes ongoing obligations on employers deploying foreign specialists, and these are monitored by the Labour Inspectorate and the migration authorities.

Key ongoing obligations include: maintaining a complete record of each foreign employee's permit status and visa validity; notifying the Employment Centre and migration authority of any change in the employee's role, location, or terms of employment (which may trigger a new permit application); ensuring that salary payments are made in accordance with the contracted terms and at or above the prescribed minimum; filing periodic reports on foreign worker headcount with the Employment Centre; and managing the departure and de-registration of workers at the end of their contract or permit period.

The Construction Inspectorate carries out site-level checks that increasingly encompass migration compliance — verifying that individuals present on site hold valid permits and are employed in roles consistent with those permits. Penalties for violations include administrative fines on the employer, expulsion of the non-compliant worker, and, in cases of systematic non-compliance, suspension of the employer's ability to obtain future quota allocations.

For companies managing Kazakhstan construction and real estate projects with rotating expatriate teams, a dedicated migration compliance function — whether in-house or through external counsel — is a practical necessity rather than an optional overhead.

Q: Can a foreign construction company apply for a work permit quota before it has a signed project contract in Kazakhstan?

A: A quota application requires the applicant to be a registered legal entity in Kazakhstan — either an LLP, a branch, or a representative office. Without legal presence, a quota application cannot be submitted. However, a foreign investor may establish a legal entity in Kazakhstan before a specific project contract is signed, provided the entity's stated business purpose covers construction-related activities. Establishing the entity and initiating the quota application in parallel with the commercial contract negotiations is a common and advisable approach, given the twelve-to-sixteen-week mobilisation timeline for third-country nationals.

Q: Do EAEU nationals working on Kazakhstan construction sites need any documentation at all?

A: Yes. While EAEU nationals — citizens of Russia, Belarus, Kyrgyzstan, and Armenia — are exempt from the work permit quota and the individual permit requirement, they are not exempt from Kazakhstani labour and migration formalities. They must: conclude a written employment contract that complies with Kazakhstani labour law; register their place of residence within thirty days of arrival; and comply with individual income tax and social insurance contribution requirements on the same basis as Kazakhstani nationals. The employer must also maintain a record of their presence and employment status. Simplified entry status is not equivalent to an absence of regulatory obligations.

Q: What happens if a work permit expires while the worker is still on site — can it be extended retroactively?

A: Retroactive extension is not available under Kazakhstan's migration framework. A permit that has expired renders the continued presence of the worker in Kazakhstan unlawful, exposing both the individual and the employer to administrative liability, including fines and possible deportation of the worker. The practical consequence for construction projects is significant: if a worker's permit expires mid-project, the employer must either have secured a renewal permit before expiry or arrange the worker's departure and re-entry once a fresh permit is issued — a process that may take several weeks. Permit renewals should be initiated at least sixty days before expiry. For companies with large rotating workforces, a permit-expiry tracking system coordinated with the site HR function is essential.

• [Market entry and company formation in Kazakhstan for foreign investors](/jurisdictions/kazakhstan/company-formation/)
• [Employment and migration law in Kazakhstan: overview for foreign employers](/jurisdictions/kazakhstan/employment-migration/)
• [Regulatory and licensing requirements for construction companies in Kazakhstan](/jurisdictions/kazakhstan/regulatory-licensing/)

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. For cross-border mandates involving Kazakhstan, the firm collaborates with contributing regional analysts and trusted local counsel admitted in Kazakhstan.

The firm's Kazakhstan coverage spans market entry, employment and migration, corporate structuring, and cross-border dispute coordination. Foreign companies deploying specialist workforces or investing in Kazakhstan's construction and real estate sector are advised to confirm their permit and compliance position before mobilisation. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

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This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.

— Aigerim Serikbayeva Contributing Regional Analyst — Kazakhstan · EAEU trade, customs and market entry vetrovpartners.com/contributions/